1. Spill Types

Spills can come in all shapes, sizes, and substances. Most spills can be grouped into one of four major categories – chemicals, oil, raw material, or air pollutants. You can use SDS sheets at your facility to identify the specifics of a potential spill.

Critical planning and prevention come into play BEFORE a spill happens. This is when you will:

Review your facility at least annually, or when a process change takes place to assess it from top to bottom,

Review any applicable regulations

Develop or update your plan(s)

Put countermeasures in place, and

Conduct training.

If all your due diligence is handled up front, you’ll be well on your way to preventing spills of all kinds – from minor slip accident to a catastrophic containment breach.

Bottom line. Spill planning is critical. If you don’t have one in place, please keep reading.

2. Spill Compliance: Top 8 Regulations

The major players in spill compliance are OSHA, EPA, and local agencies. In the infographic below, you can see a general overview of these major players. While we’ve listed the top 8 regulations related to spills, you can see that with all the local and state regulations, the regulations are countless!

Occupational Safety and Health Administration (OSHA)

OSHA is concerned about the safety of people. In the event of a spill, OSHA wants to ensure workers are kept safe from slip hazards, toxic inhalation, chemicals getting on skin, etc.

Below are our top 8 industry requirements from OSHA related to spills.

(Spill Reg #1) 29 CRF 1910.22, Subpart DAll walking and working surfaces must be kept clean and dry. When wet processes are used, drainage must be maintained and kept free of corrosion, leaks, and spills.

(Spill Reg #4) 29 CFR 1910, Subpart Z Industrial HygieneSpills can occur not only from a solid or liquid substance but also the air we breathe. These spills are commonly classified as either particulate or gas and vapor contaminants. The most common particulate contaminants include dust, fumes, mists, aerosols, and fibers. Indoor air quality is covered under 29 CFR, Subpart Z, which outlines the maximum exposure a worker is permitted for a wide range of toxic and hazardous substances.

Environmental Protection Agency (EPA)

While OSHA looks out for workplace safety, EPA is concerned about preserving waterways, soils, and quality of air. For example, will the spill leach into the ground or sewers at your facility?

(Spill Reg #5) The Resource Conservation and Recovery Act (RCRA)RCRA is the public law that creates the framework for the proper management of hazardous and non-hazardous solid waste.

The RCRA regulations are contained in title 40 of the Code of Federal Regulations (CFR) parts 239 through 282. The CFR is a collection of all federal regulations codified and enforced by all federal agencies. Title 40 – Protection of the Environment – contains all of the regulations governing EPA’s programs.

Title 40 includes standards for proper storage, containment, and management of waste at your facility.

40 CFR Part 243 covers standards for storage and collection of non-hazardous waste.

(Spill Reg #6) EPA Spill Prevention, Control, and Countermeasure rule (SPCC) The purpose of the Spill Prevention, Control, and Countermeasure (SPCC) rule is to help facilities prevent a discharge of oil into navigable waters or adjoining shorelines. The SPCC rule requires facilities to develop, maintain, and implement an oil spill prevention plan, called an SPCC Plan. These Plans help facilities prevent oil spill, and control a spill should one occur.|

Before a facility is subject to the SPCC Rule, it must meet three criteria:

It must be non-transportation-related;

it must have an aggregate aboveground storage capacity greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons; and,

there must be a reasonable expectation of a discharge into or upon navigable waters of the United States or adjoining shorelines.Every SPCC must be certified by a professional engineer (PE) unless the owner/operator is able to, and chooses to self-certify the plan.

(Spill Reg #7) Local Emergency Planning Committee (LEPC)Under the Emergency Planning and Community Right-to-Know Act (EPCRA), Local Emergency Planning Committees (LEPCs) must develop an emergency response plan, review the plan at least annually, and provide information about chemicals in the community to citizens. Plans are developed by LEPCs with stakeholder participation.

Local Goverment

In addition to EPA and OSHA federal regulations, you should also be aware of any regulations from your state environmental protection agency, the local health department, and other local government requirements.

3. Create a Spill Plan

The following spill plans may be required for your facility:

SPCC Plan (EPA): If your facility meets the criteria of EPA’s SPCC rule, you will need a certified plan in place.

ContingencyPlan (EPA): An oil spill contingency plan is a detailed oil spill response and removal plan that addresses controlling, containing, and recovering an oil discharge in quantities that may be harmful to navigable waters or adjoining shorelines. A contingency plan may be a stand-alone plan or included in an SPCC The elements of the oil spill contingency plan are outlined in 40 CFR 109.5

Emergency Preparedness and Response Plan (OSHA): If your facility meets the criteria of OSHA’s HAZWOWER standard, you will need a well-documented plan in place.

Clean Air Act State Implementation Plans (SIPs): States are required to devise and carry out state implementation plans (SIPs) to clean up dirty air and protect clean air from degradation. The Clean Air Act sets minimum requirements for measures that must be included in these plans. In Wisconsin, for example, facilities must have a Malfunction and Abatement Plan (MPAP) in place for any direct or portable source that is an “air contaminant source.”

Slug Plan: Significant industrial users (defined in 40 CFR 403.3) must have a plan to control slug discharges. Slug discharge refers to spills and batch discharges to Publicly Owned Treatment Works (POTWs). Slug plans should include:

Procedures for immediately notifying the POTW of slug discharges, including any discharge that would violate a prohibition under 40 CFR 403.5(b), with procedures for follow-up written notification within five days

If necessary, procedures to prevent adverse impact from accidental spills, including inspection and maintenance of storage areas, handling and transfer of materials, loading and unloading operations, control of plant site run-off, worker training, building of containment structures or equipment, measures for containing toxic organic pollutants (including solvents), and/or measures and equipment for emergency response.

EPA recognizes that SPPC plans or Hazardous Chemical Inventory reports may address some components of a slug plan.

If your facility does not fall into the requirements for one of the standardized plans above, it’s an industry best practice to have a plan in place if there is potential for spills at your facility.

What to Put in a General Spill Plan

Regular assessment and sign off of potential spills

Identify and document possible spill types (oil, diesel, battery acid, biohazard, raw material, air emissions, etc.). Use SDS sheets to define if it is a potentially significant spill. Document the worst-case scenario for each spill, and the potential size of the release.

Spill Prevention plan. Outline the steps you are taking to prevent and contain a possible spill.

Absorbent mats, pads, and socks to prevent spills into walkways and drains

Spill Response Plan. Make a list of who to contact in the event of a spill. Conduct employee training so your people know how to handle the spill. This includes proper training on how to shut off a machine and lockout if needed. You should also have the proper spill supplies on hand and easily accessible. This could include the following:

Spill kits

Wet Mops

PPE (safety glasses, gloves, boot covers, face mask)

First Aid

Pump

Absorbent mats or socks, or berms to quickly contain the spill

Plugging device to stop the leak

Drain protectors to minimize environmental impact

4. Spill Kit Checklist

While there are many OSHA and EPA requirements on how to be prepared for spills, the regulations do not specifically require spills kits. However, spill kits are a good best management practice under the SPCC rule. A spill kit can:

Reduce the potential of slips, trips, and falls

Reduce exposure to employees

Prevent chemical release to sewer and waterways

Be integrated as part of a quick response plan for a quick and safe response protocol

Reduce risk and limit impacts of spills

What you put in the spill kit depends on the potential spill size, type of spill, and if workers will have the appropriate PPE available.

Spill kits are generally good for spills up to around 100 gallons. After that, additional tools and methods might be needed, such as a pump.

5. What to do in the Event of a Spill

Despite all of the prevention methods put in place, spills can happen. It’s important to have a plan in place to quickly contain and stop the spill. Below are some of the key steps to properly handle a spill.

Identify the hazard

In the event of a spill, employees should be trained to quickly assess and identify the following:

Type of fluid /spill?

How much leaked, and how fast?

What is the location and direction of the spill?

Will the chemical go through ventilation systems?

Is the spill contained?

Is it incidental or hazardous?

OSHA defines an incidental release or spill as “a release of a hazardous substance which does not pose a significant safety or health hazard to employees in the immediate vicinity or to the worker cleaning it up, nor does it have the potential to become an emergency.” Incidental spills do not require an emergency response, and therefore do not require HAZWOPER-trained cleanup personnel. They may be cleaned up by employees working in the area where the spill occurred or by maintenance personnel.

Employees should know what they can and cannot cleanup in the case of a spill.

Communicate the hazard

Notify personnel and isolate the area so that others do not slip or fall. Close a nearby door if possible. Notify emergency groups such as the fire department, ambulance, EHS officer, regulatory agencies and public safety if necessary.

Contain and control

Stop the spill at the source when safely possible. Turn off the machine, plug the leak, or do what is needed to stop the spill from growing even larger. Ventilate the area if needed. Stop the spill from spreading with absorbent socks, mats, mops, or other material per your spill plan.

Clean up and decontaminate

Use appropriate spill cleanup material per your plan. This can include oil absorbents, mops, and/or a liquid pump. Decontaminate if necessary.

Always perform a root cause analysis and reassess control measures throughout your facility to prevent another spill.

Replenish any supplies used to cleanup

Replenish your cleanup supplies to ensure you are prepared for another spill.

6. Resources

There are many types of spills – from chemicals, to oil, to air pollutants. There are also many agencies that regulate the prevention and handling of these spills. Whether you meet the criteria for these spill compliance standards, you should always have a plan in place when there is the potential for a spill.

It can sometimes get confusing to keep track of who to contact and for what issue. For example, the EPA does not handle all environmental concerns, as many programs have been delegated to individual states. Here is a quick list of who to contact:

Helpful Links

Reviews

We have used ITU Absorbtech at our location for years now. Skyler always does a great job. He is very professional and efficient.read more

Kim Hoffman

18:51 30 Jan 20

ITU has been Venango Steel's uniform and mat supplier for nine years. It has been a great partnership. The quality of the products meets or exceeds expectations. Jeff Miller is our representative and Chad Prather is our route driver. They go the extra step to keep the customer happy ! Thank you Jeff & Chad !read more

Randy Groth

14:48 30 Jan 20

Our rep is Branislov and our manager is Kieth both are very friendly and give us great service. We have had ITU for over 40 years. I like what they do for "coats for kids" by cleaning all the donated clothes. Also they are a very environmentally aware company.read more

john wyszkowski

15:50 29 Jan 20

CDM Tool has been using ITU for a long time. They have dedicated drivers. Bob our driver knows our company so well, he is able to tell based on our supply's that are used how business is going. He then adjusts so we don't overpay. The best part is that they don't create more work for me. We have never had an issue with lost uniforms.read more

Krystal Smith

15:16 24 Jan 20

L&S Insulation has been a customer for many years and Absorbtech has really reliable mats, always fresh and clean. Skyler has amazing customer service and is super friendly. :)read more

Jeff Foshey

00:40 05 Feb 19

Family owned company that truly takes care of their employees and customers as if they were family!!!

Jessica Wasmuth

19:54 23 Jan 18

Customer service is great! Dave and Bernie are amazing, very helpful and respond quickly. Staff is friendly and professional.read more

Dan Behmke

16:35 20 Dec 17

Bob Casey is my route driver, very nice guy, always takes care of everything. I have been with ITU for better than 20 years, I would never change. Merry Christmas Bob C.read more

Krystle Genz

17:12 15 Dec 17

Very easy to work with. Matt is a phenomenal salesman, great personality. Brian our service representative is always very courteous and pleasant to work with. A great change for our company and glad we are doing business with them.read more

Amy Kreckler

20:37 01 Dec 17

Our company has done business with ITU for 15+ years. They give good prices and good customer service. I would recommend them. Easy to deal with. (AFI Direct Service, Inc.)read more

Deborah Young

16:16 28 Nov 17

Bob Casey is our representative and has been for many years. Bob always has a smile and is very upbeat. It is a pleasure to have Bob as our rep!read more

My Account

17:05 22 Nov 17

Bob Casey is extremely helpful and always upbeat! He always has our companies best interests in mind, making suggestions to that end and is great at communication. I look forward to working with Bob for many more years!read more

Todd Birkel

16:15 22 Nov 17

Our Route Representative, Bob Casey, is very conscientious, courteous and extremely helpful. He continually looks for areas we can improve or adjust as our usage and needs evolve, and suggest products as appropriate. Thank youread more